“…The reaction of folpet and thiophosgene with thiol groups in glutathione and proteins Siegel, 1972, 1977;Jernstrom et al, 1993;Liu and Fishbein, 1967;Lukens, 1966;Lukens et al�, 1965;Moriya et al�, 1978;Siegel, 1971aSiegel, , 1971b leads to cytotoxicity and an inflammatory reaction, with a consequent regenerative increase in cell proliferation and ultimately the development of tumors (Figure 7)� The sequence of events involving cytotoxicity and regenerative proliferation is a common mode of action for tumorigenesis by non-DNA-reactive chemicals (Meek et al�, 2003)� Cytotoxicity and regeneration is the same mode of action that has been demonstrated for the duodenal tumors induced in mice by captan (Bernard and Gordon, 2000;Gordon, 2007;2010;US EPA, 2004a)� The mode of action for folpet, including generation of thiophosgene, is similar to that seen with chloroform� Chloroform is metabolically activated to phosgene, which leads to liver and kidney cytotoxicity, regeneration, and ultimately tumors� Like folpet, this is a threshold phenomenon (Andersen et al�, 2000;Meek et al�, 2003)� Thiophosgene is not available systemically based on the chemical reactivity of folpet in the gastrointestinal tract and thiophosgene's rapid degradation in blood, in contrast to the systemic distribution of chloroform and the enzymatic generation of phosgene� In contrast to chloroform, folpet is considerably less toxic, probably related to the rapid extracellular hydrolysis leading to thiophosgene, which must then react with cells, compared to the intracellular generation of phosgene by metabolism of chloroform� Exogenous exposure to phosgene by inhalation, a highly toxic event, is unrelated to the process of the intracellular generation of phosgene from chloroform�…”